A Singapore-based Non-Resident Indian (NRI) woman earned Rs 1.35 crore from selling Indian mutual funds. She claimed tax exemption on capital gains under the India-Singapore Double Taxation Avoidance Agreement (DTAA). The tax department and Dispute Resolution Panel rejected her claim, but the Income Tax Appellate Tribunal (ITAT) Mumbai ruled in her favor, granting the exemption. The tribunal accepted her argument that a similar principle applied in a case under the India-UAE DTAA.